DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
POSTAL RATE AND FEE CHANGES,
1997
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DOCKET NO. R97-1
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INTERROGATORIES
OF UNITED PARCEL SERVICE
TO CTC DISTRIBUTION SERVICES, L.L.C.
WlTNESS JOHN L. CLARK
(UPSICTC-Tl-1
TO UPSICTC-Tl-20)
(January 20,1998)
Pursuant to the Commission’s
hereby serves the following interrogatories
witness John L. Clark (UPSICTC-Tl-1
Rules of Practice, United Parcel Service
on CTC Distribution
Servic:es, L.L.C.
through UPSICTC-Tl-20).
Respectfully
submitted,
Albert P. Parker, II
Stephanie Richman
Attorneys for United Parcel Service
SCHNADER HARRISON SEGAL 8 LEWlS
1800 Market Street, Suite 3800
Philadelphia, Pennsylvania 19103-7288
(215) 751-2200
and
1225 Eye Street, N.W., Suite 600
Washington, D.C. 200053914
(202) 463-2900
Of Counsel.
LLP
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO CTC DISTRIBUTION SERVICES, L.L.C. WITNESS JOHIN L. CLARK
UPSICTC-Tl-l .
Please refer to lines 4 through 7 on page 1 of your
testimony, where you state, “_ . CTC has grown to become the largest shipper of small
parcels to the residences
of individual consumers in the United States for the direct
marketing industry.”
(4
Identify all other “shipper[s]
of small parclsls to the
residences of individual consumers in the United States for the direc:t marketing
industry.”
(W
Provide as complete a list as possible of businesses which
CTC considers to be its competitors.
Please refer to lines 8 through 14 on page 1 of your
UPSICTC-Tl-2.
testimony, and in particular to lines 13-14, which state, “Final delivery is made by a
parcel delivery company.”
(a)
For each year from 1990 through 1997, identify all parcel
delivery companies used by CTC to make final delivery.
@I
For 1997, provide the number of parcels delivered by each
parcel delivery company used by CTC to make final delivery.
UPSICTC-TI
-3.
Provide separately for each year from 1993 through
1997 the number of parcels sent by CTC in each separate Postal Service subclass and
rate category.
-2-
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO Cl-C DISTRIBUTION SERVICES, L.L.C. WITNESS JOHN L. CLARK
UPSICTC-Tl-4.
Please refer to lines 17 through 21 on page 1 of
your testimony, where you indicate that CTC “is a user of.
carriers
local and regional
.” Please provide a list of all local and regional carriers (,a) currently used
by CTC, and, separately,
(b) used by CTC at any time during 1997 “for the final
delivery of [CTC’s] shipments”
UPSICTC-Tl-5.
(see line 21 on page 1 of your testimo~ny).
Please refer to lines 8-9 on page 2 of your testimony,
where you indicate that, “[b]y 1993, almost all of CTC’s business hacl migrated to the
Postal Service.”
(a)
Why did CTC shift almost all of its business to the Postal
(b)
Is the time in transit provided by the Postal Service
Service by 19937
acceptable and satisfactory
(cl
to CTC?
Is the overall quality of service provided tly the Postal
Service acceptable and satisfactory to CTC?
Cd)
Has any aspect of the service provided to CTC by the Postal
Service improved at any time from 1994 to the present?
If so. provide all respects in
which the Postal Service’s service to CTC has improved.
UPSICTC-Tl-6.
Please refer to lines 4 through 8 on page 2 of your
testimony, where you indicate that beginning around 1991, “CTC began offering Postal
Service delivery, as well as UPS delivery, for a final delivery option to its clients.”
-3-
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO CTC DISTRIBUTION SERVICES, L.L.C. WITNESS JOHIN L. CLARK
(4
Who selects the carrier which makes final delivery, CTC or
lb)
To the extent this decision is made by CTC. what factors
its clients?
does CTC take into account in making that decision?
(4
To the extent CTC’s clients make this decision, what have
those clients indicated to CTC about the factors they take into account in making that
decision?
UPSICTC-Tl-7.
Did CTC play any role in the development
Postal Service’s Parcel Post proposals in this proceeding?
of the
If so, please (a) describe
the role which CTC played, (b) indicate whether specific discounts or rate levels for the
various proposed new discounts were discussed by the Postal Service and CTC before
the Postal Service’s Request initiating this proceeding was filed, ancl (c) state whether
the proposed discounts or rate levels were changed during the course of those
discussions.
UPSICTC-Tl-8.
testimony.
(a) Please refer to lines 2 through 6 on page 3 of your
For 1997, provide separately the volume of packages entered by CTC at:
(1)
Origin Bulk Mail Centers;
(2)
Destination
Bulk Mail Centers;
(3)
Destination
Sectional Center Facilities;
(4)
Destination
Delivery Units.
-4-
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO CTC DISTRIBUTION SERVICES, L.L.C. WlTNESS JOHNI L. CLARK
(b)
Provide the number of Postal Service facilities at which CTC
tendered parcels to the Postal Service during 1997.
UPSICTC-TI-9.
Assuming the discounts and rates for Parcel Post
proposed by the Postal Service in this proceeding were implemented,
provide an
estimate of (a) the total number of parcels CTC will enter at Postal Service facilities in
1999 and (b) the number of parcels CTC will enter in 1999 at the following types of
Postal Service facilities:
(a)
Origin Bulk Mail Centers;
(W
Destination
Cc)
Destination Sectional Center Facilities;
id)
Destination
UPSICTC-TI-10.
Bulk Mail Centers;
Delivery Units.
When CTC tenders a shipment of ,oarcels to the
Postal Service at a Bulk Mail Center, who unloads the CTC vehicle, CTC or postal
personnel?
UPSICTC-Tl-1
I.
When CTC tenders a shipment of parcels to the
Postal Service at a Sectional Center Facility, who unloads the CTC vehicle, CTC or
postal personnel?
INTERROGATORIES
OF UNITED PARCEL SERVIC:E
TO CTC DISTRIBUTION SERVICES, L.L.C. WlTNESS JOHN L. CLARK
UPSICTC-Tl-12.
(a)
the Postal Service at a Destination
When CTC tenders a shipment of parcels to
Delivery Unit, who unloads the CTC vehicle, CTC or
postal personnel?
(b)
Service at a Destination
the Destination
When CTC tenders a shipment of parcels to the Postal
Delivery Unit, does CTC’s employees shake out any sacks on
Delivery Units platform?
UPSICTC-Tl-13.
Please refer to lines 2 through 4 on page 4 of your
testimony, where you state, “[flreedom to enter the market and compete has resulted in
more alternatives for shippers, lower costs and improved service.”
(a)
Are there more alternatives
for shippers of small parcels
now than there were in 1991?
(b)
Are there more alternatives
for shippers of small parcels
than there were in 1995?
UPSICTC-Tl-14.
Please refer to lines 13-14 on page 7 of your
testimony, where you indicate that “Priority Mail is not under consideration
sharing discounts or expanded entry options in this proceeding”
you know whether work-sharing
are under consideration?
are under consideration.
for work-
(emphasis added).
Do
discounts or expanded entry options for Priority Mail
If so, discuss your understanding
of what possible proposals
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO CTC DISTRIBUTION SERVICES, L.L.C. WlTNESS JOHN L. CLARK
Please refer to lines 9-13 on page 8 of your
UPSICTC-Tl-15.
testimony, where you indicate that “traditional
air freight companies expanded into
ground services” in the 1990’s. Identify all traditional
air freight companies that
expanded into ground services in the 1990’s as referred to in your tesitimony.
UPSICTC-Tl-16.
company to make residential
Is it generally more costly for a parcel delivery
deliveries of small parcels than to make commercial or
business deliveries of small parcels?
Which came first, the Postal Service’s initial proposal
UPSICTC-Tl-17.
of separate Destination
Please explain your answer.
Bulk Mail Center rates, or UPS’s surcharge for residential
deliveries?
UPSICTC-Tl-I
8.
Please refer to lines 16 through 18 on page 10 of
your testimony.
(a)
To what are you referring when you state, “[i]t is also
reported that parcels entered at the DBMC rate cover their direct costs and make both
a positive and significant
(b)
contribution
to the overhead costs of the Postal Service”?
Define what you mean by “direct costs” on line 17 of page
10 of your testimony.
UPSICTC-Tl-19.
Please refer to lines 5 through 8 on page 11 of your
testimony, where you refer to DBMC rates and “other parcel post improvements
-l-
from
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO CTC DISTRIBUTION SERVICES, L.L.C. WlTNESS JOHN L. CLARK
1991 to the present.”
List all Parcel Post improvements
from 1991 to ,the present there
referred to by you.
UPSICTC-TI-20.
Please state or provide an estimate of the percentage
of CTC’s parcels which are delivered to residences.
CERTIFICATE
I hereby certii
OF SERVICE
that I have this date served the foregoing
accordance with section 12 of the Commission’s
Rules of Practice.
JZ%hnE. McKeever
Dated: January 20, 1998
Philadelphia, PA
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document in